Consumer Action welcomes the opportunity to comment on the exposure draft of the National Consumer Credit Protection Amendment Regulations 2011, setting out the proposed amendment to ban exit fees on new home loans.

We support the amendments in principle and broadly in the terms of the proposed Regulations. However, we recommend that changes be made to tighten the definition of “break fee” and that, while the intention is sound, the exemption for “discharge fees” be removed. Our comments are detailed more fully below.